[rpd] RPD : Prolicy proposal "Internet Number Resources review by AFRINIC" informations update

Sat Apr 6 17:32:52 UTC 2019

Hello

I have reviewed the policy proposal and I find that part of it is 
already part of the resource assignment process reviewing a member's 
resource when necessary but not at random, this proposal is unnecessary 
and therefore I am oppose it as it is now.

At BCP 12 (https://tools.ietf.org/html/bcp12) under Section 2.1 says 
that RIR may request information about resource utilization at any time 
and if that is not available measures can be taken. I don't see a 
problem with that as long there is a motivation.

What I believe is bad and contra-productive is to make it at a random in 
a kind of 'inverted Lottery'.
When resources are allocated by the RIR there is a fair amount of checks 
that must be done to ensure its proper utilization, so by default there 
is no need to make random checks on ASNs and take that whole process in 
good faith for the time bein.
In the other hand if a ASN has been purchased or merged with another 
then it's the case to make another review. The same way it makes sense 
to conduct this procedure when there is a clear motivation as a 
complaint and elements to support a investigation.

Making random checks only serves to increase significantly the RIR 
operational costs and also the ASN's as well as most will probably be fine.

Regards
Fernando

On 06/04/2019 12:12, Arnaud AMELINA wrote:
> Hi Ernest and Co-chairs,
>
> Please find below an update of our Policy proposal "Internet Number 
> Resources Review by AFRINIC", for future discussions on the list.
>
> Regards
>
> ------------------------------------------------------------------------------- 
> Begin 
> ---------------------------------------------------------------------------------
>
>     Name : Internet Number Resources Review by AFRINIC (Draft 7)
>     Ref. Name: AFPUB-2016-GEN-001-DRAFT07
>     Status: Under Discussion
>     Date: 6 April 2019
>
> Authors:
>         (a) Amelina A. A. Arnaud | <arnaud.amelina at togorer.tg 
> <mailto:arnaud.amelina at togorer.tg>> | AUF/TogoRER
>         (b) Jean-Baptiste Millogo |<jean.millogo at orange.com 
> <mailto:jean.millogo at orange.com>>| Orange Burkina
>         (c) Marcus ADOMEY  <madomey at ug.edu.gh 
> <mailto:madomey at ug.edu.gh>> | University of Ghana
>
> 13.0 Summary of the Problem Being Addressed by this Policy Proposal
>
> As Internet Number resources are finite, their allocation is based on 
> the operational needs of end-users and Internet Services Providers, 
> while avoiding stockpiling in accordance with RFC7020, IPv4 Allocation 
> Policy CPM 5.5, IPv6 Allocation and assignment policy CPM 6.5 and 
> Policy for Autonomous System Numbers (ASN) Management in the AFRINIC 
> region CPM 7.0.Section 4 of the Registration Service Agreement (RSA) 
> provides the framework for investigations of the usage of allocated 
> Internet Number resources, defines members’ obligation to cooperate 
> and the measures to be taken by AFRINIC in case of failure to comply. 
> The lack of such investigation or regular control can lead to 
> inefficient usage of the Internet Number resources, to stockpiling and 
> other type of abuses.
>
> 13.0.1 Summary of How this Proposal Addresses the Problem
>
> In order to ensure efficient and appropriate use of resources, AFRINIC 
> shall conduct regular reviews of resource utilization held by its 
> members. This would allow recovery of any type of resource, where 
> usage is not in compliance with the RSA. Those resources can be 
> reallocated for better usage.
>
> 13.0.2 Proposal
>
> The policy proposal will modify the CPM as follows:
>
> Insert a section 13 to the CPM as follows:
>
> 13.0 Internet Number Resources Review
>
> Regular reviews of resource utilization are conducted by AFRINIC to 
> ensure efficient and appropriate usage of resources. This allows for 
> recovery of any type of resource where usage is not in compliance with 
> the RSA; to allow such resources to be reallocated for better usage.
>
> 13.1 The reviews shall be based on compliance with the terms outlined 
> in the RSA and Allocation/Assignment Policies.
>
> 13.2 The reviews cover all allocated/Assigned resources, but priority 
> goes to IPv4 and ASN mappable to two-octet ASN.
>
> 13.3 Classes of review: Members to be reviewed shall be selected 
> according to the following classes:
>
> 13.3.1 Random
>
> The member is chosen by AFRINIC at random between the membership.
>
>
> 13.3.2 Selected
>
>  Member is selected because of an internal report or due to a lack of 
> contact between the AFRINIC and the member.
>
> 13.3.3 Reported: Here, members are reviewed either because:
>
> A) They have requested the review themselves or
>
> B) There has been a community complaint made against them that 
> warrants investigation. Complaints shall be backed by evidence and 
> AFRINIC staff shall evaluate the facts as appropriate to conduct the 
> review. However this review is not applicable to a member  with the 
> same resources portfolio on which a full review has been completed in 
> the preceding 24 months.
>
>  AFRINIC staff may, at its sole discretion, after having assessed the 
> nature of the evidence found in the community complaint, require that 
> such evidence be (i) submitted in the form of a sworn affidavit or 
> (ii) declared to be true before a Commissioner of Oath.
>
> 13.4 In case of non-compliance and if evidence has been established in 
> accordance with:
>
> •    Breach of AFRINIC policies
> •    Breach of the provisions of the registration service agreement or 
> other legal agreements between the organization holding the resource 
> and AFRINIC.
>
> AFRNIC shall initiate the resource recovery process.
>
> A) AFRINIC shall attempt to contact the organization and correct any 
> discrepancy towards the RSA. Except in cases of fraudulent resource 
> acquisition or  unlawful usage and abuse, the organization shall be 
> given a minimum of six months to effect the return of the resources.
>
> If the organization is cooperative and working in good faith to 
> substantially restore compliance or has a valid need for additional 
> time to renumber out of the affected blocks, AFRINIC shall negotiate a 
> longer term.
>
> The acceptance level of compliance and duration of the longer term are 
> at AFRINIC staff discretion.
>
> B) If the situation cannot be rectified and the member did not 
> transfer the ressources to meet other AFRINIC-approved needs as per 
> adopted policies
>
>  AFRINIC shall publish the resources to be recovered for a period of 
> three (3) months; during which the organization may at any time, seek 
> compliance or transfer the ressources to other members
>
>  After this period, the resource shall be recovered and therefore the 
> records of the previous holder of the recovered resource shall be 
> updated in AFRINIC’s databases.
>
> C)  Any Internet Number Resources recovered under this policy may be 
> assigned/allocated under existing Allocation and Assignment Policies.
>
> 13.5 Appeal procedure
>
> Reviewed members who are not satisfied have the right to appeal 
> against the result within the four weeks. Appeals shall follow an 
> arbitration process as provided for in the
> Code de Procedure Civile (Code of Civil Procedure) of the Republic of 
> Mauritius. AFRINIC may, on request from an aggrieved party, suggest a 
> pool of arbitrators who shall be knowledgeable volunteers from the 
> community.
>
> 13.6 Compliance Report
>
> AFRINIC shall publish an annual meaningful report describing review 
> activities, in accordance with all applicable laws and regulations.
>
> 13.7 Acknowledgements
>
> The authors thank Ms Wafa Dahmani Zaafouri (become Afrinic GC Chair), 
> Mr Serge ILUNGA (become Afrinic Board member)  and Mr Alain P. Aina 
> for their  contributions in the development of this Policy proposal.
>
> The authors also thank the community for the discussions and 
> contributions.
>
> 4.0 Revision History
>
> 18 May 2016
>   Version 1.0
> - First Draft AFPUB-2016-GEN-001-DRAFT01
> - Posted on RPD list
>
> 05 Aug 2016
>   Version 2.0
> - Second Draft AFPUB-2016-GEN-001-DRAFT02
> - Change on the policy’s name
> - Addition of the Acknowledgement section
> - Rephrasing of section 3.3.3
>
> 18 Nov 2016
> Version 3.0
> - Third Draft AFPUB-2016-GEN-001-DRAFT03
> - Update of section 3.3.3 from discussions on mailing list
> - Update of section 3.7 (Acknowledgements) to thank the community for 
> discussions and contributions
>
> 11 Apr 2017
> Version 4.0
> - Fourth Draft AFPUB-2016-GEN-001-DRAFT04
> - Update and Rephrasing of section 3.4
> - Update and Rephrasing of section 3.5
> - Update and Rephrasing of section 3.6
>
> 21 Oct. 2107
> Version 5.0
> - Fifth Draft AFPUB-2016-GEN-001-DRAFT05
> - Adding the paragraphe C to 13.3.3. according to the legal counsel 
> proposition
> - Rephrasing the paragraphe 13.5 to comply with staff and legal 
> assessment
> - Rephrasing the paragraphe 13.6 to comply with staff assessment and 
> avoid any ambiguity
> - Changing the co-authors list
> - Updating the Acknowledgement session
> - Amending 13.4 (B) to  reflect the Transfer policies
>
> 06 Apr. 2018
> Version 6.0
> - Sixth Draft AFPUB-2016-GEN-001-DRAFT06
> - Removing categorization between membership in random class section 
> 13.3.1
>
> 06 Apr. 2019
> Version 07
> - Seventh Draft AFPUB-2016-GEN-001-DRAFT07
> - Modifying section 13.4 Paragraph A) to clarify the resources 
> recovery process: set conditions  under which a member could be given 
> longer term  to effect the return of the resources.
>
> ------------------------------------------------------------------------------- 
> End 
> ---------------------------------------------------------------------------------
>
> AAAA./
>
> Le mar. 3 avr. 2018 à 07:51, Ernest Byaruhanga <ernest at afrinic.net 
> <mailto:ernest at afrinic.net>> a écrit :
>
>     Hi Arnaud,
>
>>     On 31 Mar 2018, at 18:41, Arnaud AMELINA <amelnaud at gmail.com
>>     <mailto:amelnaud at gmail.com>> wrote:
>>
>>     Dear PDWG,
>>     As you can see through the Lagos PPM minutes [1],  all  pending
>>     legal concerns  have been addressed. Last suggestion  received
>>     abiut removing categories in section 13.3.1( make the random
>>     selection applies to all members)  was  accepted by working group
>>     and  will reflect  in the next version  to come.
>>
>>     While awaiting the new version, please send any new comments,
>>     suggestions you may have on the proposal [2]
>>
>>     [1]
>>     https://afrinic.net/fr/library/policies/archive/ppm-minutes/2261-afrinic-27-pdwg-meeting-minutes
>>     [2]
>>     https://afrinic.net/fr/community/policy-development/policy-proposals/2231-internet-number-resources-review-by-afrinic
>
>     Please send the new version well ahead of the recommended CPM
>     3.4.2 deadline to allow reasonable time for staff's assessment of
>     the updated proposal.
>
>     Regards,
>     Ernest.
>
>
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